ITAT allowed the assessee's appeal and quashed the revisional order passed u/s 263. It was held that the AO had conducted adequate enquiry regarding the purchase and sale of listed shares, including verification of banking records, demat statements, broker confirmations, and STT-paid transactions. The assessee was found to be a regular investor, and the source of funds and genuineness of the transactions were duly established. Since no discrepancy or falsity in the evidence was alleged or proved, the assessment order could not be termed "erroneous and prejudicial to the interests of the Revenue" merely because the PCIT held a different view. Consequently, the addition contemplated u/s 68 did not survive.
ITAT allowed the assessee's appeal and quashed the revisional order passed u/s 263. It was held that the AO had conducted adequate enquiry regarding the purchase and sale of listed shares, including verification of banking records, demat statements, broker confirmations, and STT-paid transactions. The assessee was found to be a regular investor, and the source of funds and genuineness of the transactions were duly established. Since no discrepancy or falsity in the evidence was alleged or proved, the assessment order could not be termed "erroneous and prejudicial to the interests of the Revenue" merely because the PCIT held a different view. Consequently, the addition contemplated u/s 68 did not survive.
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